Ezel / IRS Rulings / 200947047

CCA 200947047: TEFRA partnership AAR filing recommendation

Number
200947047
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Administrative Adjustments Requests
Topics
Procedure, penalties, and administration
Code sections
§ 6227, § 6110
Publicly released
November 20, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This Chief Counsel advice recommends that the tax matters partner of a TEFRA partnership file Form 8082 as an administrative adjustment request. The amended Forms 5471 and 5472 should be attached. If those forms provide distinct filing instructions, the tax matters partner should comply with those instructions separately.

Ruling snapshot

  • Question: How should a TEFRA partnership's tax matters partner file an administrative adjustment request involving Forms 5471 and 5472?
  • Outcome: Advice given
  • Key authorities: IRC § 6227; Form 8082

Full text (IRS public release)

ID: CCA_2009100816354654 Number: 200947047
Release Date: 11/20/2009
Office: --------------
UILC: 6227.00-00

From: --------------------------
Sent: Thursday, October 08, 2009 4:35:46 PM
To: -------------------------------------------------------------------------------------------
Cc: ------------
Subject: RE: TEFRA Partnerships and FBAR Filing Requirements ---------

We recommend that the tax matters partner of the TEFRA partnership file a Form 8082 AAR, with the
amended Forms 5471/5472 attached. To the extent that Forms 5471/5472 provide distinct filing
instructions, the tax matters partner should also separately comply with those instructions.

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